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  • Who signs Revenue Regulations (Rev Regs)?
  • What is willful blindness?
  • Can a memorandum of assignment be considered a valid LOA to authorize a Revenue Officer to audit a taxpayer?
  • When is a tax assessment deemed made?
  • Which statement best describes the function of withholding programs in tax administration?
  • The protest must be filed within how many days from receipt of the FLD or FAN?
  • What is the importance of the 15-day period to file a reply to the PAN?
  • What is the role of Himlayang Pilipino in relation to LOA?
  • How do third-party information reporting forms support tax administration?
  • Who is authorized to prepare returns, provide tax advice, and represent taxpayers in examinations and collection matters when authorized?
  • How is taxpayer confidentiality protected in data processing and information sharing?
  • Legislative rules require what before adoption?
  • Which of the following sets correctly lists three core taxpayer rights emphasized in modern tax administration?
  • If the BIR does not act after 180 days, which remedy involves filing an appeal with the CTA within 30 days after the lapse of 180 days?
  • What is the general statute of limitations for assessment, and what are common exceptions?
  • Who issues the LOA that authorizes examination of a taxpayer's books?
  • Which of the following is NOT a typical stage in the IRS examination and appeals process?
  • Does the 30-day period to appeal to the CTA start after the administrative remedy has been exhausted?
  • In the Oplan Kandado process, which sequence correctly describes the steps leading to the 48-hour notice under Oplan Kandado?
  • What is the effect of a taxpayer's failure to respond to a Notice of Discrepancy?
  • Which of the following is NOT typically used in risk assessment to select returns for audit?
  • Which statement correctly describes the irrevocability rule for tax credit options?
  • Under Presidential Decree No. 242, who has authority to resolve administrative disputes involving agencies of the Executive Branch?
  • If a report required by law as a basis for assessment is not forthcoming or is believed false, how shall the Commissioner proceed?
  • Which statement describes the modes of service of the eLA correctly?
  • Can the government pursue distraint and levy and file a civil or criminal action at the same time?
  • Can the CIR obtain taxpayer information from other government agencies?
  • Which statement best describes the role of Appeals during the IRS examination process?
  • A criminal complaint filed before the Justice Secretary with an attached affidavit by a revenue officer containing a computation of the taxpayer's tax liabilities: is this an assessment?
  • What are the two types of surcharges?
  • Which description describes deficiency interest?
  • After sale in a seizure to enforce a tax lien, what happens to the sale proceeds that exceed the tax plus costs?
  • Surveillance findings may serve as basis for assessment but remain subject to what due process concept?
  • For reinvestigation, the 180-day period is reckoned from which date when supporting documents are submitted?
  • How many days are you given to submit the supporting documents in relation to a reinvestigation?
  • What is the effect if the BIR fails to comply with its formal requirements for a waiver of prescription and what are the jurisprudential exceptions?
  • What does Form 8821 authorize?
  • What is an Offer in Compromise (OIC), and on what basis might it be approved?
  • What is the purpose of a Notice of Intent to Levy and the available taxpayer protections?
  • Which law governs confidentiality of tax return information in the United States, and what is its purpose?
  • What is the correct period for the Commissioner to decide on the protest?
  • What is a Letter of Authority (LOA) in the context of tax assessment?
  • How should taxpayers respond to IRS notices if they disagree with the proposed position?
  • When does an assessment become a Disputed Assessment?
  • Who determines what documents are relevant and sufficient for a reinvestigation?
  • Which court has exclusive jurisdiction over cases involving the validity or constitutionality of tax laws, rules, and regulations?
  • When a substantially amended return is filed, from which filing may the three-year prescriptive period be reckoned?
  • Which principle is violated if the government proceeds with tax collection without PAN informing the taxpayer?
  • Which of the following constitutes a violation of the 15-day period to reply?
  • What mechanism helps protect privacy when external parties access confidential taxpayer data?
  • Which court has exclusive original jurisdiction over criminal cases with attendant claim amounting to Php1,000,000 or more?
  • What is the required response upon receiving a 48-hour notice under Oplan Kandado?
  • Sec. 250 of the NIRC provides P1K penalty (max P25K for each calendar year) for each failure to file information returns or keep records or supply information. When will a person NOT be liable for this penalty?
  • In civil tax cases, who bears the burden of proof on most issues, and how does this differ in criminal tax cases?
  • Does mere underdeclaration automatically establish falsity under Section 222(a) when pursuing a ten-year prescriptive period?
  • To avoid the assessment becoming final, by when must the taxpayer submit all relevant supporting documents in a reinvestigation?
  • Which option reflects a general power of the CIR related to personnel?
  • What are the grounds for abatement?
  • Which action is NOT recommended to protect against identity theft during the filing season?
  • In the Court of Tax Appeals, if the administrative claim is defective, will the judicial claim proceed under de novo review?
  • What is reasonable cause, and how can it influence penalty abatement?
  • Under RMO 14-2016, which requirements must be met for a valid waiver of the statute of limitations?
  • What does Form 2848 authorize?
  • In a reinvestigation protest, what must be specified?
  • Relevant supporting documents are defined as documents necessary to support the legal bases in disputing a tax assessment as determined by the taxpayer.
  • Does Sec. 5 allow inquiry into bank deposits?
  • Under RMC No. 82-2022, LOA remains valid even if served beyond 30 days provided what condition holds?
  • Is the Memorandum of Assignment (MOA) authorizing a Revenue Officer to conduct an audit valid?
  • For criminal cases with attendant claim below Php1,000,000, original jurisdiction is vested with which forum?
  • In CIR v. First Express Pawnshop, why did the Court rule that the Bureau cannot demand what type of specific documents should be submitted?
  • Under Sec. 222(a) of the NIRC, what triggers extending the period to assess to 10 years?
  • What are penalties if a taxpayer fails to obey summons?
  • Under which provision can the CIR make assessments based on his own knowledge?
  • What are statutory notices, and how do they support tax disputes?
  • What does 'Currently Not Collectible' mean in tax collections?
  • What are the typical stages of the IRS examination and appeals process?
  • Which of the following is a listed instance under Sec. 223 of the NIRC when the running of the prescriptive period is suspended?
  • Which statement about withholding programs is accurate?
  • Why are professional ethics essential in tax administration?
  • What is the purpose and typical outcome of an Appeals conference in tax administration?
  • Which describes deficiency interest?
  • Under Sec. 203 NIRC, within what period must internal revenue taxes be assessed?
  • If civil action instituted before criminal action, which proceeds first?
  • What does a Notice of Intent to Levy allow the taxpayer to do?
  • How should tax administrations balance fairness and equity in enforcement across different taxpayer circumstances?
  • When should the administrative or judicial protest (after receiving an FDDA) be filed?
  • Which statement best describes the role of data analytics in identifying tax compliance risk?
  • If an FDDA fails to state the facts and legal basis on which it is based, what is the effect on the 30-day period to appeal to the CTA?
  • Which document informs the taxpayer of the proposed deficiency tax assessment but does not demand payment?
  • What are common penalties that may be assessed for noncompliance, and what is their overarching purpose?
  • What are the two kinds of administrative issuances defined in Fortune Tobacco v CIR?
  • True or False: In cases within CTA jurisdiction, the criminal action and the corresponding civil action for the recovery of civil liability for taxes and penalties shall be deemed jointly instituted in the same proceeding, with no right to reserve filing of the civil action separately.
  • Does the Commissioner's power to issue a subpoena duces tecum extend to third parties not under audit?
  • Under RMO 54-00, surveillance shall be classified as three types. Which of the following is NOT one of them?
  • What is the nature and extent of a tax lien under Sec. 219 of the NIRC?
  • A compromise penalty is a sum proposed by the BIR to settle what liability?
  • From an administration perspective, how is a frivolous tax return defined?
  • Which statement is true regarding the prescriptive period when a protest is pending?
  • What is the difference between a tax lien and a levy?
  • Under Oplan Kandado, what is the minimum duration of closure for a non-compliant establishment?
  • FDDA must include which of the following as part of its essential content?
  • Which of the following is NOT an essential content of a final decision on the disputed assessment (FDDA)?
  • When is a tax lien valid against third parties such as purchasers or mortgagees?
  • Which statement correctly states the Grounds for compromise and the applicable minimum percentages of the basic tax due?
  • Who were the Revenue Officers specifically authorized by LOA to examine the books of accounts?
  • According to CIR v. Metro Star Superama, Inc. (2010), why is the issuance of a Preliminary Assessment Notice (PAN) essential before collecting deficiency taxes?
  • What is the maximum penalty under Sec. 250 per calendar year for failure to file information returns or keep required records?
  • What is the rule regarding irrevocability of the carry-over option for excess tax credits?
  • How does third-party data verification support risk assessment?
  • Which statement best contrasts seizure under forfeiture and seizure to enforce a tax lien?
  • Who approves a request for reinvestigation?
  • Which statement about identity theft response teams is accurate?
  • In tax assessments, the burden of proof is on the taxpayer to demonstrate error in accordance with which case?
  • Which of the following statements about fraud penalties is most accurate?
  • Which factor is considered when evaluating an Offer in Compromise?
  • Under Section 222(a) of the Tax Code, when may a collection proceeding occur without prior assessment?
  • What is the purpose of Form 8821 (Tax Information Authorization) in agency communication?
  • If the FDDA is void, can it count as a final decision for the purposes of the 30-day appeal period?
  • Which statement about protest types is true?
  • What are the two functions of a LOA?
  • Why did the CIR prevail in Garcia v. Collector of Internal Revenue regarding confiscation and recovery of unpaid taxes?
  • Why are accurate third-party reporting requirements (W-2s, 1099s) essential to tax administration?
  • Which of the following are rights or powers of the BIR that can prescribe?
  • What does a Letter of Authority allow access to?
  • Under Section 6(A), NIRC, within how many years from the date of filing can a return be modified, changed, or amended, provided no notice for audit or investigation has been served?
  • How should new information provided by a taxpayer be treated during an audit?
  • Under Sec. 11 of RA 1125, when the Court of Tax Appeals suspends collection, the taxpayer may satisfy the suspension by which action?
  • What is the difference between a Power of Attorney (Form 2848) and a Tax Information Authorization (Form 8821)?
  • Can delinquency and deficiency interest be imposed simultaneously?
  • What is the primary purpose of confidentiality agreements with contractors handling tax data?
  • What is a common reason that a PAN might be considered improperly served?
  • What is the proper remedy when a taxpayer challenges an adverse CIR ruling interpreting a provision of the NIRC?
  • Under Sec. 228, which statement is correct regarding the need for a LOA when a preassessment notice is not necessary?
  • What is the primary objective of tax administration within a government agency?
  • What is Fast Track Settlement (FTS) in tax administration?
  • Provide an example of tax collection jeopardizing government interest.
  • When contractors handle confidential taxpayer data, what measures should tax administrations implement?
  • Which of the following actions is included in the CIR's powers related to tax liability adjustments?
  • Under the non-retroactivity of rulings by the BIR, which of the following are exceptions?
  • What is the key takeaway from Lapanday Foods Corporation v. CIR regarding reckoning period?
  • After receiving a 5-Day VAT Compliance Notice, how long does a taxpayer have to refute the BIR's findings and submit a formal response?
  • How do notices of deficiency differ from standard audit adjustments in terms of appeal rights?
  • What are the two remedies available after receiving an FDDA?
  • Which statement best describes the CIR's subpoena power in relation to third parties?
  • What are the two main protest methods available to taxpayers challenging a BIR assessment?
  • In the MarieBank case, CIR did not act on an administrative refund claim. MarieBank filed a judicial claim before the CTA. The CIR moved to dismiss arguing that the judicial claim was defective because the administrative claim was incomplete. What happened?
  • What is a Collection Due Process (CDP) hearing?
  • Which of the following is an indicator that a taxpayer may be the victim of identity theft in tax matters?
  • Is an assessment required before filing criminal charges for tax evasion?
  • After the Discussion of Discrepancy, if liability remains, within how many days must a deficiency tax assessment in the form of a PAN be issued?
  • What is the difference between a correspondence audit and a field audit?
  • Under the McDonald's v CIR decision, what are the due process requirements when invoking the 10-year extension period?
  • Which of the following is not a typical safeguard protecting taxpayer confidentiality in data processing?
  • How is the Court of Tax Appeals organized in terms of divisions and leadership?
  • What is the general period for the right to assess deficiency tax?
  • How do tax administrations respond to identity theft and refund fraud?
  • Which of the following is NOT a recognized method to maintain books of accounts under RMC No. 029-19?
  • Which statement about the Preliminary Assessment Notice (PAN) is true?
  • What steps can taxpayers take to protect themselves from identity theft in filing season?
  • TRUE or FALSE: Revenue Officers must serve the LOA within thirty days from its issuance.
  • Which of the following describes the civil remedies available to the government for delinquent taxes?
  • What does a compromise penalty do?
  • Under the Best Evidence Obtainable rule, assessments are prima facie presumed to be correct; where does the burden of proof lie?
  • If a taxpayer does not adequately respond during an audit, which of the following best describes the typical next step?
  • Which action is explicitly listed as a ground for suspension or temporary closure of a business under Oplan Kandado?
  • When is criminal liability considered complete?
  • In cases of inaction of the CIR on the protested assessment, can these remedies be availed simultaneously?
  • Which form authorizes disclosure of confidential tax information to a designated representative for tax matters?
  • What is the typical path from a taxpayer protest to litigation?
  • Mere underdeclaration of income automatically constitutes a false return under Section 222(a) of the NIRC?
  • What does due process require in tax administration?
  • Which is an example of an exception to bank secrecy as stated in Sec. 6(F) of the NIRC?
  • Under Sec 7 of the NIRC, to whom may the CIR delegate the powers vested in him?
  • Does a Preliminary Assessment Notice constitute a demand for payment?
  • What triggers the accuracy-related penalty concerning substantial understatement, and how are thresholds determined?
  • What is the purpose of a Letter of Authority (LOA) in tax assessment?
  • Does the Court of Tax Appeals have jurisdiction over tax assessment disputes when both parties are government agencies?
  • In a reinvestigation protest, what beyond standard content must be specified?
  • Which statement best describes a tax lien?
  • In most tax examinations, who bears the burden of proof for substantiating items on the return?
  • Which rule or statute governs the 30-day period to appeal after an FDDA?
  • When does the interest on underpayments begin to accrue?
  • Which of the following is an essential content of a protest?
  • A collection notice that merely reiterates earlier findings without addressing the protest is valid.
  • What distinguishes surveillance from a tax audit?
  • Why is it necessary to issue another LOA when revenue officers are reassigned to examine the book of accounts?
  • Who is the current presiding justice of the Court of Tax Appeals?
  • What is the role of an Enrolled Agent or CPA before the IRS?
  • How can taxpayers reduce identity theft risk during the filing season?
  • What best describes a Revenue Regulation (Rev Reg)?
  • Joel Mendez profession and duty.
  • To be valid, what must the 5-Day VAT Compliance Notice include?
  • Which of the following is a general power of the CIR?
  • What is an installment agreement, and when is it used?
  • How does risk assessment influence which returns are selected for audit?
  • In Garcia v. Collector of Internal Revenue (1938), who is correct about recovering unpaid taxes after confiscation of the subject alcohol?
  • Which statement correctly describes the CTA's divisions and division leadership?
  • What is a typical administrative protest process within the IRS?
  • How should eLA service by mail be effected?
  • If a person fails to file a required return or files a false return, what action may the Commissioner take?
  • What is the function of a Notice of Deficiency, and what is the taxpayer's time to contest it?
  • Which statement best describes the requirement for the basis of a tax assessment to be valid?
  • May the Commissioner conduct surveillance under Section 6(C) of the NIRC before the formal issuance of a Letter of Authority (LOA)?
  • Before a case can be brought to the Court of Tax Appeals, which layer may be involved for executive-branch disputes?
  • What must be proven for the government to suspend tax collection under RA 9282 Section 11?
  • Which statement best describes a tax levy?
  • What is the role of an IRS Appeals officer?
  • Interpretative rules have what consequence?
  • Which of the following describes a typical outcome of an Appeals conference?
  • What did Medicard Philippines, Inc. v. CIR hold regarding LOA?
  • What is the purpose of a hearing after a Notice of Intent to Levy?
  • Does the presumption of prima facie correctness apply if a tax assessment has no factual or legal basis?
  • If the CIR denies the protest, which statement is true?
  • Which scenario would most likely support a reasonable cause abatement?
  • Under Avon case, a demand letter for immediate payment issued while a protest is pending can be treated as the final decision if it clearly shows the BIR intends to collect and will not act on the protest.
  • How many divisions comprise the Court of Tax Appeals and how many Justices serve per division?
  • What is the role of revenue officers in the collections process?
  • How are fraud penalties applied and what additional actions may accompany them?
  • Why might penalties be abated, and what typical bases support abatement requests?
  • Why is it important to uphold the statute of limitations in tax assessment and collection, as explained in CIR v. Philippine Global Communications, Inc.?
  • Who issues the 48-hour notice after approval by the Review Board in the Kandado process?
  • What are the two remedies available to the Taxpayer if the BIR does not act on the protested assessment after 180 days?
  • What is Innocent Spouse relief, and when might it apply?
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